ML20034A709
| ML20034A709 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/17/1990 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9004240164 | |
| Download: ML20034A709 (3) | |
Text
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Southem Calibmia Edison Company 23 PARKER STREET BRVINE. CALarORNIA 92718 MAROLD B. MAY TEtt> HONE vect **Etipsht tes est-amop l
April 17, 1990 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 l
Gentlemen:
Subject:
Docket Nos. 50-206, 50-361, and 50-362 I
Reply to a Notice of Violation San Onofre Nuclear Generatina Station ~
Units 1, 2.
and 3 i
Reference:
Letter, Mr.
G.
P. Yuhas (NRC) to Mr. Harold B. Ray (SCE), dated March 19, 1990 The Reference forwarded NRC Inspection Report No. 90-08 and a Notice of Violation (NOV) resulting from the routine inspection conducted by Mr. K. M. Prendergast during the period of February 26 through March 2, 1990.
In accordance with 10 CFR 2.201, the enclosure to this letter provides the Southern California Edison (SCE) reply to this NOV.
If you have any questions, or if you require additional information, please let me know.
Sincerely, Enclosure cc:
John B. Martin, Regional Administrator, NRC Region V C. W. Caldwell, NRC Senior Resident Inspector, San Onofre j,f$b f
e.
j a
4 1
ENCLOSURE.
REPLY TO A NOTICE OF VIOLATION I
Appendix A to~Mr. Yuhas' letter dated March 19, 1990,- states in part:
"A.
Technical Specification-6.8.1' requires written' procedures to.
~
bel established, implemented, and maintained covering the Emergency Plan.
Emerg ncy~ Plan implementing procedure SO123-VIII-0.200,
'Ene...;u.ncy Plan-Drills,' Revision ~1',
dated October 24,'1988,:
Atta; ament 1, regnicaa a post accident sampling;systemi i
(PASS) drill to be preformed annually.
Contrary to the above, the licencee failed to. performed. _
(sic] the annual PASS drill as required by.the above. stated procedure.
The last PASS drill was conducted' December 6,-
1988.
l
^
This is a severity level'IV violation (Supplement VIII)."
1
RESPONSE
1 1.
Reasons for'the violation. if admitted An annual post accident sampling. system: (PASS); drill, as specified in. Station Emergency Plan Implementing:ProcedureL
- [
SO123-VIII-0.200, " Emergency Plan Drills,":was not performed' in 1989.
The drill was missed as a result of personnel 1 error involving the failure to follow SO123-VIII-0.200 as.-
written.
A PASS drill had been planned for lateL1989,-to be held 1
separately from quarterly drills.
The intent of this. drill i
was to satisfy all annual and biennial post-accident sampling-related requirements'of the-San Onofre Nuclear Generating Station (SONGS) Emergency Plan.
Following the last quarterly drill Tnt October 23, L1989, an-i internal request was made to cancel the biennial PASS cask-portion of the drill for 1989.
In response to this request, the individual cognizant for reviewing drill requirements failed to refer to SO123-VIII-0.200, relying only on a e
review of the Emergency Plan itself.
This Emergency Plan review overlooked the annual post accident sampling procedure drill requirement.
consequently, because a i
n
-~
i
' Reply to a Notice of Violation biennial PASS cask drill had been completedDin December.
n 1988, the 1989: drill was cancelled due to the mistakenL l
belief that only a biennial requirement existed which.did not need to be satisfied until 1990.
2.
Correceive stees that have been taken and the results-5 achieved i
~The individual who performed the' Emergency' Plan _ review and-erroneously concluded-that.no annual. post accident sampling-drill requirements existed is noclonger-employed byfSCE;!
however, in the future,. requests'for drill cancellation or s
postponement will'be' approved by the manager responsible for=
drill execution.
~
t While investigating the circumstances. leading.to the missed post accident sampling, drill, Lit wasinotedithat SO123-VIII-^i 4
0.200 does not contain all appropriate: requirements specified.in the Emergency Plan.
SO123-VIII-0.200,
" Emergency Plan Drills," Revision 1, does:not address the-exiv.tence of both post accident sampling-related drills, each having differing frequencies'and specifications:- the-procedures drill 1(required annually)<and'the cask-drill 1
(required biennially).
1 I
In recognition of this procedure. weakness,la reviewLof the:
SONGS Emergency Plan:has been initiated 5tojensure all required drills have'been identified'and properly; characterized in implementing procedures.
Upon completion of the review of the Emergency; Plan, SO123-VIII-0.200 will be revised accordingly.
The Emergency Plan' review,1and' resulting changes to SO123-VIII-0.200,' will be; completed by May 15, 1990.
3.
Corrective stens that will be taken to avoid further violations i
An annual post accident sampling ~ procedures drill will be' completed by May 15, 1990.
4.
Date when full comoliance will be achieved I
Full compliance will be achieved on May 15, 1990, by which time the-annual post accident sampling: procedures drill will have been completed.
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